TXX-6250, Responds to Violations & Deviations Noted in Insp Repts 50-445/86-15 & 50-446/86-12 in June 1986,per 870120 & 0202 Telcon Requests for Listed Extensions.Corrective Actions: Procedures Revised & Engineering Evaluation Performed
| ML20209H856 | |
| Person / Time | |
|---|---|
| Site: | Comanche Peak  |
| Issue date: | 02/02/1987 |
| From: | Counsil W TEXAS UTILITIES ELECTRIC CO. (TU ELECTRIC) |
| To: | NRC OFFICE OF INFORMATION RESOURCES MANAGEMENT (IRM) |
| References | |
| TXX-6250, NUDOCS 8702060154 | |
| Download: ML20209H856 (22) | |
Text
_ _ _ _ - _ _
Log # TXX-6250 Filc# 10130 IR 86-15 IR 86-12 M
RE:
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nlELECTRIC February 2, 1987
%ilham G. (cumil 1 mwne the l>rsklent U. S. Nuclear Regulatory Commission ATTN: Document Control Desk j
Washington, DC 20555
SUBJECT:
COMANCHE PEAK STEAM ELECTRIC STATION (CPSES)
DOCKET NOS. 50-445 AND 50-446 RESPONSE TO NRC NOTICE OF VIOLATION INSPECTION REPORT NOS. 50-445/86-15 AND 50-446/86-12 Gentlemen:
We have reviewed your letter dated December 22, 1986, concerning the inspection conducted by Mr. I. Barnes and other members of the Region IV Comanche Peak Group during the period June 1-30, 1986. This inspection covered activities authorized by NRC Construction Permits CPPR-126 and CPPR-127 for Comanche Peak Steam Electric Station Units 1 and 2.
Attached to your letter were Notices of Violations and Deviations.
On January 20, 1987, per a telecon with your Mr. Ian Barnes, we requested and received an extension as follows:
IR 50-445/86-15 and 50-446/86-12 (8 violations, 5 deviations) extended until January 30, 1987, with the following exceptions: V-05, V-07 extended until February 6, 1987.
On February 2, 1987, per a telecon with your Mr. Ian Barnes, we requested and and received an extension as follows:
IR 50-445/86-15 and 50-446/86-12 (8 violations, 5 deviations) extended until February 3, 1987, with the following exception: V-07 extended until February 6, 1987.
We hereby respond to the Notices of Violations and Deviations in the attachment to this letter.
l Very truly yours,
$$W14 W. G. Counsil RDD/gj c - Mr. E. H. Johnson, Region IV Mr. D. L. Kelley, RI - Region IV Mr. I. Barnes, - Region IV
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Attachment TXX-6250 Page 1 of 21 NOTICE OF VIOLATION ITEM A (446/8612-V-01)
A.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 Quality Assurance Plan (QAP), requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Section 3.2 of Brown & Root (B&R) Procedure CP-CPM 6.3, Revision 11, requires the person completing an operation on a traveler to. sign or initial "... at the completion of each operation and prior to moving parts c' assemblies to the next scheduled operation."
Contrary to the above, travelers for conduit and junction box supports in the Unit 2 reactor building and safeguards building were routinely left unsigned until an entire conduit run was completed. Travelers were being signed during a " final walkdown" prior to QC inspection, with the person signing the traveler not necessarily the same person who performed the operation.
(446/8612-V-01).
RESPONSE TO ITEM A (446/8612-V-01)
We admit to the violation and the requested information follows:
1.
Reason for Violation The Violation resulted from inadequate requirements specified in Section 3.2 of CP-CPM 6.3, " Preparation, Approval and Control of Operation Travelers." The intent of this section has always been to allow construction personnel to sign for completion of operations at any time after completion of the work. However, CP-CPM 6.3 did not accurately reflect this intent.
2.
Corrective Steos Taken and Results Achieved Since the practice of deferring traveler sign-offs until final walkdown provides the necessary verification of design and installation requirements, no corrective actions are required for existing documentation or installations.
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations Revision 12 to CP-CPM 6.3 was issued July 14, 1986. This revision clearly allows craft personnel to sign or initial the traveler after completion of the work provided the operation is of such a nature that post-construction verification is possible. Training of appropriate construction personnel j
was completed July 23, 1986, for Revision 12 to CP-CPM 6.3 4.
Date When Full Comoliance Will Be Achieved Full compliance was achieved July 23, 1986.
Attachment TXX-6250 Page 2 of 21 NOTICE OF VIOLATION ITEM B (446/8612-V-02i B.
Criterion V of Appendix B to 10 CFR Part 50, as implement'ed by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented _ instructions, procedures, or drawings of a type appropriate to the circumstances.
Paragraph 3.1.4.1 of B&R Procedure CEI-20, Revision 9, requires Hilti anchor bolts to be set by the use of a torque wrench at the time of installation.
Contrary to the above, Hilti bolts on conduit and junction box supports in the Unit 2 reactor building and safeguards building were being installed using an ordinary ratchet wrench. Torquing of these bolts was usually performed only on a " final walkdown" by craftpersons prior to QC inspection.
(446/8612-V-02)
RESPONSE TO ITEM B (446/8612-V-02)
We admit to the violation and the requested information follows:
1.
Reason for Violation The violation was the result of a misunderstanding on the part of construction personnel regarding the requirements for bolt setting specified in CEI-20, " Installation of 'Hilti' Drilled-in Bolts." The initial tightening of Hilti bolts during installation was not considered as " setting" by some construction personnel. They believed that bolt setting, to the minimum torque values specified in CEI-20, was to be accomplished during final fixture installation and/or walkdown.
2.
Corrective Steps Taken and Results Achieved Since construction personnel used torque wrenches to verify the final installation, undertorquing of the Hilti bolts is not an issue.
We have performed an engineering evaluation of the potential effects of overtorquing the Hilti bolts. As documented in memo NE-1297, the evaluation indicates that application of torques in excess of those required to set the bolt, using non-calibrated wrenches, would have no impact on the ability of the anchor to meet its design requirements.
The evaluation also indicates that, in the unlikely case where extreme overtorquing occurred, the effects would be. apparent and would result in Quality Control rejection of the installation-For the above reasons we believe that no corrective actions are required for existing installations.
Attachment TXX-6250 Page 3 of 21 NOTICE OF VIOLATION RESPONSE TO ITEM B (446/8612-V-02) CONT'D 3.
Corrective Steos Which Will Be Taken To Avoid Further Violations All appropriate construction personnel have been retrained to the requirement of CEI-20, with emphasis on using torque wrenches for the initial setting of Hilti bolts. This training was completed December 12, 1986.
4.
Date When Full Comoliance Will Be Achieved Full compliance was achieved December 12, 1986.
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8 Attachment TXX-6250 Page 4 of 21 NOTICE OF VIOLATION ITEM C (446/8612-V-03)
C.
Criterion III of Appendix B to 10 CFR Part 50, as implemented by Section 3.0, Revision 3, dated July 31, 1984 of the TUGC0 QAP, requires in part, s
that measures must be established to assure that applicable regulatory requirements and design basis, as defined in Part 50.2 and as specified in the license application, for those structures, systems, and components to which this appendix applies, are correctly translated into specifications, drawings, procedures, and' instructions.
The design control measures must provide for verifying or checking the adequacy of design, such as by the performance of design reviews, by the use of alternate or simplified calculational methods, or by the performance of a suitable testing program.
In addition, design changes, including field changes, must be subject to design control measures commensurate with those applied to the original design.
Section 1.6 of Appendix B to Gibbs & Hill (G&H) Specification 2323-ES-100 Revision 2, and Section 3.6.1 of B&R Procedure ECP-19A, Revision 2, both require NEMA Type 4 enclosures in the reactor building.
Contrary to the above, enclosures are installed in the Unit 2 reactor building which have been modified. The modifications occurred with no design control and without verification that the modified enclosures meet the design requirements.
(446/8612-V-03)
RESPONSE TO ITEM C (446/8612-V-03)
We admit to the violation and the requested information follows:
1.
Reason for Violation The violation was caused by improper implementation of a design change by both engineering and construction personnel in that; 1) engineering personnel directed a design change via an NCR and verbal instructions, and l
- 2) construction personnel accepted the NCR and verbal instructions as sufficient authorization to perform work without the design change and l
subsequent design authorization.
The design change which was improperly implemented consisted of a minor fastener alteration to upgrade the NEMA Type 12 electrical enclosure to a NEMA Type 4 for use in the reactor building.
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2.
Corrective Steos Taken and Results Achieved l
A Design Change Authorization (DCA) to Specification 2323-ES-100,
" Electrical Erection Specification," will be issued to allow the upgrade of NEMA Type 12 enclosure to a NEMA Type 4.
Upon issuance of the DCA, Procedure ECP-19A, " Installation of Class 1E and Non Class 1E Conduit Raceway Systems" will be revised to reflect this revised requirement.
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Attachment TXX-6250 Page 5 of 21 NOTICE OF VIOLATION RESPONSE TO ITEM C (446/8612-V-03) CONT'D 3.
Corrective Steos Which Will Be Taken To Avoid Further Violations The electrical engineering and construction warehouse group will be reinstructed to ensure they understand the necessity of using an approved Design Change Authorization (DCA) to implement design changes.
A directive was issued December 9, 1986, by the Vice President of Engineering and Construction, to all engineering and construction personnel, reiterating the requirements for the proper implementation of design changes. The directive specifically addressed the problem of engineering personnel specifying design changes and construction personnel performing design changes without an approved DCA.
4.
DateWhenFullComplianceWillBeAchieYed The DCA to Specification 2323-ES-100 will be issued no later than March 2, 1987.
The revision to Procedure ECP-19A will be issued no later than March 16, 1987.
Reinstruction of the electrical engineering and construction warehouse porsonnel will be completed by March 23, 1987.
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Page 6 of 21 NOTICE OF VIOLATION ITEM D (446/8612-V-04)
D.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Section 2.20.5 of G&H Specification 2323-ES-100, Revision.2, and Section 3.6.1 of B&R Procedure CP-CPM-7.3, Revision 1, require that tools used on stainless steel materials shall not be contaminated by use on other materials.
. Contrary to the above, tools used to cut stainless steel flexible conduit were also used on carbon steel conduit and other. items.
(446/8612-V-04)
RESPONSE TO ITEM D (446/8612-V-04) 4 j
We admit to the violation and the requested information follows:
i 1.
Reason for Violation The violation resulted from a failure of implementing procedures to i
adequately'specify tool segregation controls. The requirement that, "any tools used on stainless steel materials shall not be contaminated with
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particles from other materials," is included in Specification 2323-ES-100, j
" Electrical Erection Specification," as part of the general measures for i
. cleanliness and chemical contamination control. However, these measures
.were not. implemented in any procedure applicable to the electrical field fabrication shop. Construction Procedure CP-CPM-7.3, " General Fabrication Procedure" applies only to the activities of the structural iron fabrication shop.
2.
Corrective Steos Taken And Results Achieved To address the specific concerns cited in the Violation, we have performed an evaluation of the potential effects of cutting stainless steel conduit with blades previously used to cut carbon steel. The evaluation (documented in memo NE-1297) indicates the following:
a)
The affected conduit areas (cut surface) are not subject to stress conditions as structural support is provided by the coupling assemblies which contain the conduit ends.
b)
The conduits are not submerged nor is there any great probability of high humidity or excessive moisture during normal operating conditions.
If enough excessive moisture did collect to develop a galvanic cell, the resultant corrosion would only attack the cut end of the conduit. The cut end, due to the use of coupling assemblies, provides no mechanical function.
Attachrent TXX-6250 Page 7 of 21 NOTICE OF VIOLATION RESPONSE TO ITEM D (446/8612-V-04) CONT'D 2.
Corrective SteDs Taken And Results Achieved (con't) c)
The unlikely development of a thru-will pit would have negligible and insignificant impacts on the conduit as no pressure boundary of fluid tight requirements exist.
For the above reasons no harmful effects will result.
No corrective actions are considered necessary for existing installations.
3.
Corrective Steos Which Will Be Taken To Avoid Further Violation In accordance with the above evaluation, a design change (DCA-25,208, Rev.
- 1) was issued September 18, 1986, to exempt conduit and other specific electrical stainless steel components from tool segregation requirements.
Construction Procedure ECP-19A, " Installation of Class IE Conduit Raceway System" was revised January 7,1987, to clearly state that segregation of tools used on carbon steel from stainless steel is not required for electrical components.
4.
Date When Full Comoliance Will Be Achieved Full compliance was achieved January 7,1987.
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Attachment TXX-6250 Page 8 of 21 I
NOTICE OF VIOLATION ITEM E (446/8612-V-05)
E.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
B&R Procedure CP-CPM 4.1, Revision 0, requires that work activities shall be suspended when design drawings.and specifications cannot be complied with and a design change shall be requested from engineering. Work may resume after receipt of the approved design change document.
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Contrary to the above, examples have been identified with respect to conduit and junction box supports in which work was not suspended when design drawings and specifications could not be complied with, and modifications were made without prior engineering approval and the required appropriate design documents.
(446/8612-V-05) i l
RESPONSE TO ITEM E (446/8612-V-05) l We admit to the violation and the requested information follows:
1.
Reason for Violation The violation was caused by a failure of electrical construction personnel to comply with the requirements of CPM-4.1, " Construction Requests for i
Engineering Design Changes." The non-compliance with the procedure is attributed to a lack of documented training of electrical construction personnel on the requirements of CPM-4.1.
2.
Corrective Steos Taken And Results Achieved Training of the electrical construction personnel in the requirements of Construction Procedure CPM-4.1 was completed August 6,1986.
In addition, on August 17, 1986, CPM-4.1 was included in the mandatory training matrix requirements for electrical construction personnel.
Although engineering approval was not obtained prior to electrical construction personnel performing modifications, engineering approval was i
obtained on the final installations. Therefore, no additional corrective action is required for existing installations.
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Attachment TXX-6250 Page 9 of 21-NOTICE OF VIOLATION RESPONSE TO ITEM E (446/8612-V-05) CONT'D 1
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations _
The CPM 4.1 design change requests are not routinely used by construction groups other than the electrical group.
For these other groups, the requirements to obtain engineering approval prior to performing modifications are contained in various task specific procedures.
Additionally, all construction personnel are trained on these requirements as part of their initial site indoctrination. To reinforce these measures, a directive was issued December 9, 1986, by the Vice President of Engineering and Construction, to all engineering and construction personnel, reiterating that any modifications must have prior engineering i
approval.
4.
Date When Full Comoliance Will Be Achieved Full compliance.was achieved December 9, 1986.
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Attachment TXX-6250 Page 10 of 21 NOTICE OF VIOLATION ITEM F.1 (445/8615-V-06)
F.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above:
1.
No procedures or instructions existed for Unit 1 paper flow group (PFG) to control design documents (e.g., drawings) issued for extended periods. B&R Procedure CP-CPM-6.3 only specifies control for such documents issued on a daily basis. NRC inspection of 50 design documents issued to the onsite fabrication shop for extended periods found them to be maintained current; however, there were no procedures documenting how this activity was to be accomplished. NRC inspection of the Unit 2 PFG procedures found that the procedures for control of documents issued for extended periods were documented.
(445/8615-V-06)
RESPONSE TO ITEM F.1 (445/8615-V-06)
We admit to the violation and the requested information follows:
1.
Reason for Violation The violation was caused by a management oversight in failing to provide specific instructions for the control of design documents issued for extended periods.
Please note, general instructions for the instances observed in the finding were provided per Section 3.1.2 of CP-CPM 6.3,
" Preparation, Approval and Control of Operation Travelers."
2.
Corrective Steos Taken And Results Achieved i
As stated in the violation, there is no evidence that work was being performed using incorrect revisions of design documents. Therefore, no corrective actions are considered necessary for existing installations.
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations In order to provide additional direction to the Unit 1 Paper Flow Group for the review of packages on extended issuance, the following procedures were revised per DCN 1 to revision 0 of the procedures and issued July 25, 1986.
i CP-CPM 7.4
" Unit 1 PFG Package Flow Control" l
CP-CPM 7.4A " Appendix A Package Preparation" Please note, these procedures were superceded by issue of revision 3 to the following procedures on December 15, 1986 due to a combination of the Unit 1 and Unit 2 Paper Flow Groups.
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' Attachment TXX-6250 Page 11 of 21 NOTICE OF VIOLATION RESPONSE TO ITEM F.1 (445/8615-V-06) CONT'D Corrective Steos Which Will Be Taken To Avoid Further Violations (cont'd)
CP-CPM 7.1
" Package Flow Control" CP-CPM 7.1A " Appendix A Documentation Package Preparation" 4.
Date When Full Comoliance Will Be Achieved Full compilance was achieved July 25, 1986.
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Attachment TXX-6250 Page 12 of 21 NOTICE OF VIOLATION ITEM F.3 (445/8615-V-08: 446/8612-V-08)
F.
Criterion V of Appendix B to 10 CFR Part 50, as implemented by Section 5.0, Revision 3, dated July 31, 1984, of the TUGC0 QAP, requires that activities affecting quality shall be prescribed by and accomplished in accordance with documented instructions, procedures, or drawings of a type appropriate to the circumstances.
Contrary to the above:
B&R Procedures CP-CPM-7.3A, Revision 0, and CP-CPM-8.1, Revision 3, did not provide instructions relative to defining what information must be included on written requests to the onsite fabrication shop for fabricated items. For example, the onsite fabrication shop has received requests for fabricated items on three-part memos that did not specify whether the item was Q or non-Q, ASME or non-ASME, its location and intended use, and whether it was temporary or permanent. This information is necessary to assure compliance with QA requirements.
(445/8615-V-08; 446/8612-V-08)
RESPONSE TO ITEM F.3 (445/8615-V-08: 446/8612-V-08)
We admit to the violation and requested information follows:
1.
Reason for Violation The violation was the result of inadequacies in Construction Procedure CP-CPM-7.3A, " Material Storage / Identification for Structural Fabrication."
By failing to standardize the means by which shop fabricated items were i
i requested, no measures were established to assure adequate quality or technical requirements were implemented during the fabrication process. A preliminary survey of the requests submitted using non-standard forms indicates the non-standard form was not generally used for fabrication of safety-related parts, components or assembly.
2.
Corrective Steos Taken And Results Achieved A review of all fabricated items requested on non-standard request forms has been initiated to verify that proper inspections were performed and material traceability was maintained where the fabricated items were installed in quality related systems and components. Nonconformance reports will be initiated in the event discrepancies are identified.
3.
Corrective Steos Which Will Be Taken To Avoid Further Violations Procedure CP-CPM-7.3 was revised August 12, 1986, to specify a standard request form to request shop fabricated items. Training has been accomplished.
The incorporation of redundant requirements in CP-CPM-8.1,
" Receipt, Storage and Issuance of Items" is not required, l
Attachment TXX-6250 Page 13 of 21 NOTICE OF VIOLATION RESPONSE TO ITEM F.3 445/8615-V-08: 446/8612-V-08) CONT'D 4.
Date When Full Comoliance Will Be Achieved The review of items fabricated per non-standard requests will be completed no later than March 6, 1987.
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Attachment TXX-6250 Page 14 of 21 NOTICE OF DEVIATION ITEM A (445/8615-D-01)
A..4, " Inspector Education and Experience Requirements and Capabilities for Level II Inspection, Examination and Test Personnel" ofCPP-003, Revision 3, states, in part, that the experience requirements for certification of a high school graduate are "..
3 years of related experience in equivalent inspection, examination, or testing activities.
In deviation from the above, a certified Level II overview inspector's experience was found not to meet the requirements of Attachment 6.4.
The-3 years experience used as a basis for certification was verified as a
" Project Receipt Inspector," which does not appear to be equivalent related experience for the certified position of " Level II Mechanical / Welding Inspector" (445/8615-D-01).
RESPONSE TO ITEM A (445/8615-D-01)
We admit to the deviation and requested information follows:
1.
Reason for Deviation ERC investigation confirmed that the documentation describing the subject inspector's verified experience did state that the individual was a
" Project Receipt Inspector" for the time period indicated. This was determined to have been caused by a clerical error. The document used to verify the inspector's experience did not completely describe the individual's job functions.
2.
Corrective Steos Taken and Results Achieved Further clarifying verification concerning this individual was obtained on August 12, 1986. The verification confirmed the individual's employment as a "MARF Project Receipt Inspector and S&G Project NAVSHIPS/AWS/ASME Inspector", therefore the individual is qualified as a Level II Inspector.
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Corrective Steos Which Will Be Taken To Avoid Further Deviations All qualification / certification packages have been subsequently reviewed.
The deviation identified was determined to be an isolated case.
Therefore, no action to prevent recurrence was required.
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Date When Full Comoliance Will Be Achieved Full Compliance was achieved on August 12, 1986.
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Attachment TXX-6250 Page 15 of 21 NOTICE OF DEVIATION ITEM B.1 (445/8615-D-03) 8.
Section 4 of Revision 4 to ERC Procedure CPP-009 for Issue-Specific ActionPlan No. VII.c states, in part, " Qualified QA/QC Review Team personnel perform field reinspections of specific hardware items and reviews of appropriate documents in accordance with approved instructions Section 4 of Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the onsite QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 (CPP-009)...." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ Effective Change Notice (s), the OI (0verview Inspector) denotes whether the item is (un) acceptable...."
Section 5.4.3 of ERC-QA-28 states, in part, "The OI compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies In deviation from the above, the following errors were identified concerning the results of overview inspections:
1.
Overview inspection (01) Package No. 12-I-M-SBC0-078 failed to identify an unsatisfactory decision made by the initial ERC inspector.
During an NRC inspection, one condition was identified of pipe to pipe clearance in violation of Section 5.2.6.2 of ERC Quality Instruction (QI) QI-026, Revision 2. However, the initial ERC reinspection as well as the overview inspection failed to identify this deviating condition (445/8615-D-03).
RESPONSE TO ITEM B.1 (445/8615-D-03)
We admit to the deviation and requested information follows:
I.
Reason for Deviation The exact cause of this deviation is indeterminate, other than inspector error. However, investigation by ERC has confirmed that a clearance violation did exist and that both the overview and reinspection failed to identify it.
2.
Corrective Steos Taken and Results Achieved The Overview Verification Package No.12-I-M-SBC0-078 was revised on July 9,1986, to identify the clearance violation.
Deviation Report I-M-SBC0-078-DR2 was initiated on October 7, 1986, to document the clearance violation. Additionally, TV Electric has prepared Nonconformance Report No. M-28933N to address this deviation.
' Attachment TXX-6250 Page 16 of 21 NOTICE OF DEVIATION RESPONSE TO ITEM B.1 (445/8615-D-03) CONT'D 3.
Corrective Steos Which Will Be Taken To Avoid Further Deviations The findings were discussed with all overview inspectors and the reinspector on June 10, 1986, and July 11, 1986, respectively. These discussions were documented.
4.
Date When Full Comoliance Will Be Achieved CPRT compliance was achieved on October 7,1986. TU Electric compliance will be achieved coincident with the final disposition of NCR M-28933N.
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' Attachment TXX-6250 l
Page 17 of 21 I
NOTICE OF DEVIATION ITEM B.2 (445/8615-D-04)
.B.
Section 4 of Revision 4 to ERC Procedure CPP-009 for Issue-Specific ActionPlan No. VII.c states, in part, " Qualified QA/QC Review Team 4
personnel perform field reinspections of specific hardware items and l
reviews of appropriate documents in accordance with approved instructions
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Section 4 of Revision 2 to ERC Quality Assurance Procedure ERC-QA-28,
" Performance of Overview Inspections," states, in part, " Qualified QA/QC Review Team personnel assigned to the onsite QA Representative perform Overview Inspections of work performed in accordance with Reference 3.1 l
(CPP-009)...." Section 5.4.2 of ERC-QA-28 states, in part, " Based upon each accept / reject criterion specified in the referenced QI/ Effective Change Notice (s), the OI (Overview Inspector) denotes whether the item is t
(un) acceptable...."
Section 5.4.3 of ERC-QA-28 states, in part, "The OI compares the results of the Overview Inspection with the results of the initial reinspection / documentation review to identify any apparent inconsistencies 7
l In deviation from the above, the following errors were identified j
concerning the results of overview inspections:
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2.
Paragraph 5.2.1 in Section 5.0 of QI-037, Revision 1, states, in part, l
" Verify that pipe clamp halves are parallel...." In addition, of QI-037 states, in part, "iS' dimensions on the same side of the clamp at points 1, 2 and 3 shall be within 1/16" of each other to be acceptable. Also, the clamp shall not be more than 1/16" out of i
parallel from side to side at points 1, 2 and 3 to be acceptable."
i Measurements for S1 recorded by the initial ERC inspector showed a difference between points 1 and 3 of 1/8", which was 1/16" out of tolerance.
Similarly, measurements recorded for S2 showed a difference between points 1 and 3 of 5/32", which was 3/32" out of tolerance. The corresponding values for the out of tolerance conditions recorded on ERC l
deviation report I-S-PS7N-095-DR1 were 1/32" and 1/16", respectively.
The deviation report incorrectly identified the degree of being out of tolcrance.
The overview inspection failed to identify and resolve these j
discrepancies (445/8615-D-04).
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' Attachment TXX-6250 Page 18 of 21 NOTICE OF DEVIATION RESPONSE TO ITEM B.2 (445/8615-0-04) CONT'D We admit to the deviation and the requested information follows:
1.
Reason for Deviation A review by ERC of deviation report I-S-PS7N-095-DR1 revealed that a mathematical error had been made by reinspection which resulted in an inaccurate description of the out of tolerance condition.
2.
Corrective Steos Taken and Results Achieved The Overview Inspector discussed the above described mathematical error with reinspection. Deviation report I-S-PS7N-095-DR3 was initiated on September 16, 1986, superceding I-S-PS7N-095-DR1. Deviation report I-S-PS7N-095-DR3 provides an accurate description of the out of tolerance condition.
3.
Corrective Steos Which Will Be Taken To Avoid Further Deviations ERC performed an independent review of all completed Overview and associated Reinspection packages to ensure that all inconsistencies between the verification packages had been appropriately addressed.
4.
Date When Full Comoliance Will Be Achieved Full Compliance was achieved on September 30, 1986.
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Attachment TXX-6250 Page 19 of 21 NOTICE OF DEVIATION ITEM C (445/8615-D-05 AND 446/8612-0-06)
C.
Section 4.1 of ISAP No. I.d.1, Revision 2, states that for Phase I,
" Training, qualification, certification and recertification files for all electrical QC inspectors, for all current ASME inspectors, and for the remaining current non-ASME inspectors will be reviewed against project requirements...." to identify those inspectors whose certifications or qualifications were questionable.
In deviation from the above, the ERC Phase I review failed to identify lapses in recertifications of TUGC0 electrical inspectors.
ERC Phase I review also failed to identify that an electrical inspector's recertification to CP-QP-11.3 did not specify the activities or restrictions which were applicable to the recertification (445/8615-D-05; 446/8612-D-06).
RESPONSE TO ITEM C (445/8615-D-05 AND 446/8612-D-06)
We admit to the deviation and requested information follows:
1.
Reason for Deviation ERC has reviewed the NRC concern for the electrical inspector's certification records and agrees that a lapse had in fact occurred for a period of approximately eight (8) days for QI-QP-11.3-28, and approximately six (6) days for QI-QP-ll.3-29, 40, and 44.
The ERC failure to identify this discrepancy was due to an apparent oversight, therefore, a deviation does exist. However, confusion exists as to the exact date of recertification due to the many dates contained on the training forms.
A deviation does not exist for the identification that an electrical inspector's recertification to CP-QP-II.3 did not specify the activities or restrictions which were applicable to the recertification.
ERC identified on the Inspector Certification Evaluation Summary (ICES) the failure to exclude the requirements of QI-QP-ll.3-42 on December 17, 1985.
Based on the ICES, an NCR was prepared (NCR No. E-85-201318) which addressed the failure to exclude QI-QP-ll.3-42, 2.
Corrective Steos Taken and Results Achieved ERC has prepared a memorandum (QA/QC-RT-5506, dated January 20,1987) addressing lapses in inspector certifications. TV Electric has initiated a generic Non conformance Report, NCR No, M-86-104861 to address breaks in periods of certification. Additionally, the quality training supervisor has initiated a review of the TU Electric non-ASME file for certification lapses which includes the aforementioned deviation.
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Attachment TXX-6250 Page 20 of 21 NOTICE OF DEVIATION RESPONSE TO ITEM C (445/8615-D-05 446/8612-D-06) CONT'D 3.
Corrective Steos Which Will Be Taken To Avoid Further Deviation ERC has provided memos addressing this generic problem of lapses in inspector certification. TV Electric is addressing this concern on a case by case basis as evidenced by NCR M-86-104861.
4.
Date When Full Como11ance Will Be Achieved CPRT compliance was achieved on January 20, 1987. TU Electric compliance is on-going as evidenced by generic NCR M-86-104861 dated November 4, 1986.
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' Attachment TXX-6250 Page 21 of 21 NOTICE OF DEVIATION ITEM D (445/8615-D-10)
D.
Section 5.2 of QI-010, Revision 3, states, in part, " Verify that the field assembly / modifications are complete and in accordance with the applicable drawings."
In deviation from the above, NRC inspection of Verification Package No. I-E-EEIN-075, a Unit 1 diesel generator control panel, revealed that ERC inspectors failed to identify the following:
1.
A jam nut was loose on one of the six floor mounting bolts.
2.
Sheet 2 of component layout Drawing 52383 did not delineate installed relays R12A and R128 (445/8615-D-10).
RESPONSE TO ITEM D (445/8615-0-10)
We deny the deviation for the reasons that follow:
- 1.
The loose jam nut is not considered within the scope of QI-010. However, an out-of-scope (00S) observation has been prepared and processed. The OOS No. is 1065.
2.
Relays 12A and 128 are not shown on Drawing 52383 but are documented on DCA 17854, Rev. 2.
The sketches attached to the DCA which show the location of these relays do not specifically identify which relay (12A and 12B are identical) is installed in which side of panel CPI-MEDGEE-01A (left or right). - However, the ERC inspector was able to discern the correct panel side location for relays 12A and 128 by examining the wiring i
diagrams attached to the DCA. Relay 12A is shown on a wiring diagram as part of the Channel 1 Class 1E Start Circuit whereas relay 128 is shown on i
another wiring diagram as part of the Channel 2 Class IE Start Circuit.
The Channel 1 Start Circuit diagram includes the statement " Located in Enclosure Left Side of Panel"; the Channel'2 diagram says " Located in Enclosure Right Side of Panel". Thus, the ERC inspector was able to verify dimensional location for relays 12A and 128 in the left and right sides of the panel, respectively.
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